https://www.taxtmi.com/caselaws?id=65375 The ITAT allowed the appeal for statistical purposes, remanding the case to the AO for a fresh examination of the additional evidence regarding the Permanent Establishment (PE) in India. The AO must reconsider the tax liability and interest under section 234B, guided by the Motorola Inc. decision. The Tribunal underscored the importance of thoroughly assessing the additional evidence to accurately determine the PE's presence and activities in India. en-us Fri, 08 Dec 2006 00:00:00 +0530 Fri, 01 Mar 2024 15:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=65375 The ITAT allowed the appeal for statistical purposes, remanding the case to the AO for a fresh examination of the additional evidence regarding the Permanent Establishment (PE) in India. The AO must reconsider the tax liability and interest under section 234B, guided by the Motorola Inc. decision. The Tribunal underscored the importance of thoroughly assessing the additional evidence to accurately determine the PE's presence and activities in India. Case-Laws Income Tax Fri, 08 Dec 2006 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=65375